Upper House passes Bill providing for tax entity emergency repair measures

The Upper House of the Dutch Parliament on 23 April 2019 passed the proposed legislation providing for tax entity emergency repair measures, which had been sparked by a ruling by the European Court of Justice concerning the application of restrictions on interest deductibility in prevention of profit shifting. Both the Netherlands Corporation Tax Act 1969 and the Netherlands Dividend Tax Act 1965 are having to be amended in line with the emergency repair measures. Some of the changes in question are to take retroactive effect from the first of January 2018 onwards. The debate on the Bill involved a motion being tabled, and voted down, in which the Cabinet was asked to prepare a policy memorandum setting out criteria governing retroactively effective tax measures.

Dutch version: Wetsvoorstel spoedreparatie fiscale eenheid aangenomen